During a recent audit, Independence identified an issue caused by a
provider?s subcontractor separately billing Independence and/or our members for
services that the subcontractor and its agent provided at the request of the
provider.
As a reminder, all providers must notify Independence of any subcontractor
agreements, in accordance with their Professional Provider Agreement and/or
Hospital, Ancillary Facility, or Ancillary Provider Agreement (Agreement). If
the subcontractor bills Independence and/or our members and Independence makes
payments on any claims as a result of the providers? subcontracting agreements,
the provider will be responsible for reimbursing Independence for payments from
the subcontractor and/or the subcontractors? agents? billing.
An example of a subcontractor arrangement that caused Independence to
recover payments from a provider is a hospital that subcontracted for
Intraoperative Neuromuscular (INM) Testing services from a vendor (INM
subcontractor). The INM subcontractor separately billed Independence and our
members. Independence?s reimbursement includes payment for the operating room
services rendered by the participating hospital?s INM subcontractor, as the
services were required by the surgeon to complete the surgery. The services of
all such similar technicians, such as a radiology technician or pulmonology
technician are also included in the hospital?s reimbursement, including when
the hospital subcontracts for such services. In this example, the hospital?s
INM subcontractor?s claims included charges from an agent of the INM
subcontractor, who is not on the hospital?s medical staff and is not a
participating provider with Independence.
The hospital subcontractor billed and collected payments from Independence
and our members. Hospitals are obligated under the terms of their Agreement to
hold Independence and our members harmless from subcontractors, including the
subcontractors? agents. Independence recovered these payments from the hospital
that subcontracted for the services.
If you have any questions concerning a current audit, please send a detailed
inquiry to ProviderAuditInquiries@ibx.com.